One compliance strategy across CII, EU ETS and FuelEU
A mid-size dry-bulk operator (anonymized)
Illustrative case study. Client identity is anonymized and figures represent the class of outcome MarineAware targets, not a specific contracted result.
Challenge
With 100% EU ETS coverage from January 2026, the first FuelEU Maritime penalties landing by mid-2026, and several vessels drifting toward a CII "D" rating, the operator faced three overlapping regimes with different metrics and no coherent view of total exposure.
Approach
We built a bottom-up emissions model from AIS activity multiplied by vessel-specific fuel curves, calibrated against the fleet's verified EU MRV totals so the numbers were MRV-grade. On top we modelled cost across CII, EU ETS, FuelEU and UK ETS, optimised FuelEU pooling and banking, and ran weather routing that trades voyage time against fuel and CII penalty.
Outcome
The operator now has a per-vessel, per-voyage compliance cost model, a defensible plan to lift at-risk vessels off a "D" rating, and emissions figures its lenders and charterers accept under the Poseidon Principles.
This engagement is representative of MarineAware’s decarbonization work. Figures are illustrative of the class of outcome we target and are anonymized to protect client confidentiality.
The overlap is the problem
CII rates operational carbon intensity A–E. EU ETS puts a price on covered emissions. FuelEU Maritime caps the well-to-wake GHG intensity of the energy a ship uses. UK ETS adds a parallel layer for UK-touching trades. Each has its own boundary, metric and penalty — and optimising for one can quietly worsen another.
The only way through is a single model that speaks all four languages at once and expresses the answer in the currency owners actually care about: euros per voyage and euros per year.
MRV is the ground truth
AIS-derived emissions estimates are only credible if they reconcile to something verified. EU MRV publishes per-ship annual CO₂ and fuel for vessels over 5,000 GT calling at EU ports. Calibrating the activity model against those verified totals is what lets a lender or charterer trust the number — and what separates a real compliance strategy from a spreadsheet guess.